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NEW

REGULATIONS
AND RULES FOR
ATEX DIRECTIVES
THE OPERATOR'S VIEWPOINT OF
THE EUROPEAN EXPLOSIVE ATMOSPHERE (ATEX) DIRECTIVE 94/9/EC

INCE 1 JULY 2003, TWO NEW EUROPEAN DIRECTIVES

S commonly called ATEX directives have considerably modified the rules

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for selection and use of equipment in hazardous areas. ATEX is a French
acronym for “atmospheres explosibles,” i.e., explosive atmospheres.
ATEX Directive 94/9/EC (see reference (1))(also sometimes referred as 100a/95), some-
times called the “product” directive, affects the manufacturers. ATEX Directive
1999/92/EC, (see reference (2)) sometimes called the “user” directive, affects the workers.
This article deals only with directive 94/9/EC, since this directive
applies to products that exist in an oil and gas company under the respon-
sibility of the electrical, instrumentation engineers. Directive 1999/92/EC
(also sometimes referred as 118/137), which applies to users and defines the
minimum requirements for improving the safety and health protection of
workers, is under the responsibility of the Safety division (HSE). Yet there
is a link between the two directives, and the technologist engineer cannot
ignore the “user” directive.
These new ATEX directives are called the “New Approach,” a new
method for the total harmonization of regulations covering this field.
The approach aims to ensure free movement of the products to which
©ARTVILLE, LLC. it applies by removing barriers to trade. It also aims to improve the
safety of products and users.

BY PATRICK LEROUX 43

1077-2618/07/$25.00©2007 IEEE
The New Approach concept was built upon in the Situation after 1 July 2003 (The New Approach)
early 1980s for application in the year 2000. Today,
about 20 European directives based on the New ATEX Directive 94/9/EC Summary
Approach concept are in force. The main advantage of The directive can be summarized as follows.
the New Approach is that it is no longer necessary to
make an adaptation to technical developments Framework
(amendments to standards, standards harmonization, This directive
new directive, transposition in national laws) in order ■ makes no direct references to standards
to keep up with technical developments. In the past ■ defines essential health and safety requirements
with the old directive (“Old Approach”), it was neces- (EHSRs)
sary to update the directive to transpose it into ■ applies to electrical and nonelectrical equipment
national laws after an amendment to standards since ■ applies to environments that are potentially explo-
the application of the European CENELEC standards sive due to gas and dust hazards
(each of them describing a type of protection: d, p, i, ■ takes into consideration all potential hazards that
e) was imposed by the directive. These procedures equipment may cause, in particular at the design
generated a lot of red tape! and production levels
■ applies both to mines susceptible to fire damp and
Situation Prior to 1 July 2003 (The Old Approach) surface industries
1) European regulations concerning electrical equip- ■ recognizes the European Standards Committee
ment for potentially explosive atmospheres were (CEN) and the European Committee for Elec-
based on European directives, which require regu- trotechnical Standardization (CENELEC) as compe-
lar modification in the form of application or adap- tent bodies to define the required harmonized
tation to directives to keep up with technical standards
developments. ■ defines procedures for the assessment of conformi-
2) The basic European text in this field was the ty to essential requirements, on the basis of mod-
76/117/EEC directive, which provided the general ules that qualify equipment to carry the CE
framework for regulations to allow the free circula- marking, which is the passport for sale into
tion of goods within the European Union (EU). EU/EFTA countries.
3) Electrical equipment for use in potentially explo-
sive atmospheres were certified by a state- Comparison of the Old and New Approaches
approved body, often referred to as the Equipment no longer must be in compliance with a series
“laboratory,” when it met the relevant European of CENELEC standards as under the Old Approach, but
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standards (EN 50014 and upwards) covering now must satisfy EHSRs. This is the spirit of the “New
each type of protection (d, i, e, p, etc.). Such Approach” directive, and this is a major change. In short,
equipment was then issued a European certificate it can be said that with the new directive, there is an
of conformity, entitling it to carry the distinctive obligation of results (to meet the EHSRs) and not of
Epsilon x mark. This mark opens the way to means (application of imposed standards). Any standard
trading within the EU and even on occasion out- may be used provided that it meets the EHSRs.
side this territory. The new directive has introduced a global concept
4) This system had been in operation for many years. for safety (risks other than electrical risks are now
Although largely beneficial, it has certain draw- included, such as high surface temperature on pipes
backs, notably a lack of flexibility and the absence and mechanical friction). It also has introduced the
of a global concept of safety. It is going to be con- surveillance of manufacture periodically to ensure that
siderably modified by the new European directive the certified product continues to comply with the
94/9/EC published 23 March 1994. Application requirements of the directive.
of directive 94/9/EC before 1 July 2003 was made The application of the harmonized CENELEC stan-
on a voluntary basis but has been mandatory since dards gives only a presumption of conformity to the direc-
this date in all the EU and European Free Trade tive, whereas in the past it was considered as full
Association (EFTA) countries.Certificates of con- conformity. The list of harmonized CENELEC standards is
formity to harmonized standards obtained in published in the European Community (EC’s) official jour-
compliance with previous directives remains valid nal. When harmonized standards do not exist, other stan-
until 30 June 2003, but their validity will only dards may be applied according to an internally approved
cover conformity to the harmonized standards list [between all the Ex notified bodies (NBs)] with an
specified in these directives. order of preference.
5) The system of certification relating to the
76/117/EEC directive—with a “certificate of con- ATEX Directive 94/9/EC
formity” for equipment in strict compliance with
CENELEC standards and an “inspection certifi- What Type of Equipment Is Affected by ATEX?
cate” for equipment not strictly in accordance with 1) Equipment: machines, including internal combus-
CENELEC standards but offering at least a degree tion engines, apparatus, fixed or mobile devices,
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of safety—is no longer valid. control and instrumentation components, etc.
2) Protective systems: explosion relief systems, flame Nonelectrical Equipment
arresters, etc. ATEX Directive 94/9/EC also applies to nonelectrical
3) Components: items essential to the safe function- equipment (mechanical, hydraulic, and pneumatic
ing of equipment and protective systems but with equipment). Nonelectrical equipment include single
no autonomous function, including terminals, push pieces of equipment (pump, valve), combined equipment
button, relays, empty flame proof enclosures, ballast (such as an explosion protected forklift), and assemblies
for fluorescent lamps, etc. (packages such as a pump driven by a motor fitted on a
4) Safety, controlling, and regulating devices: skid associated or unassociated with auxiliaries). All of
devices intended for use outside potentially these configurations are within the conformity assess-
explosive atmospheres but required for the safe ment procedures.
functioning of equipment or protective systems Process areas (chemical, refinery) and complete produc-
with respect to the risk of explosions (controller tion plants are also assemblies of equipment. They are con-
units for sensors temperature, pressure, flow, gas structed from numerous pieces of equipment, but they are
detectors, power supply to an EEx “i” measure- not placed on the market as a product and are not subject
ment system used for monitoring process para- as a unit to conformity assessment procedures. Yet it is
meters, etc.). possible to “certify” a complete plant as a unit (as per
Another example of a safety device largely used Annex IX of the directive), but on a voluntary basis and
in Europe is the protection relay (installed in safe not by law.
area) for an EEx “e” motor that must be certified Potential and effective ignition sources shall be
because it must trip with a tripping time below assessed, including the ignition risks that arise from dust
the Te time defined by the standard EN 50019. If or other material trapped between fixed and moving parts.
the tripping time occurs above the Te time, the New types of protection have been defined in a new
rotor will reach an internal temperature above the series of CEN standards, EN 13463-1 to -8, as follows:
authorized temperature class T, generally ■ Basic methods and requirements EN 13463-1
= 200◦ C in oil and gas production activities. ■ “fr” Flow restricting enclosure EN 13463-2
This means that the motor may cause an explo- ■ “d” Flame proof enclosure EN 13463-3
sion because it has not been designed to with- ■ “g” Inherent safety EN 13463-4
stand to an internal explosion. ■ “c” Constructional safety EN 13463-5
This is not the case for an EEx “d” motor. Here ■ “b” Control of ignition source EN 13463-6
the protection relay need not be certified because if ■ “p” Pressurisation EN 13463-7
the relay fails to trip, the motor will reach an inter- ■ “k” Liquid immersion EN 13463-8
nal temperature above the authorized temperature The type of protection outlined in “c,” constructional

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class T, which may cause an explosion. Yet the EEx safety, is particularly directed towards mechanical equip-
“d” motor has been designed to withstand to an ment (pump, compressor, fan, gear, etc.). One important
internal explosion; this is the major difference aspect is that good equipment construction can keep the
between “d” and “e” motors. (Also, the cost of a probability of faults that could lead to the ignition
“d” motor is approximately double that of an “e” sources so low that the equipment meets the require-
motor.) These safety devices were not covered by ments of the relevant categories. This means that this
the old directive. type of protection may be used for all categories, even for
category 1. Yet, if this is not sufficient to meet the cate-
What Type of Equipment Is Excluded by ATEX? gory 1 requirements, another type of protection may be
■ medical devices intended for use in a medical included. It is worth noting that the essential require-
environment ments may also be met without the application of the
■ equipment and protective systems where the explo- above harmonized standards.
sion hazards result exclusively from the presence of For many decades, mechanical equipment has been
explosive substances or unstable chemical substances used extensively in Europe, the United States, and else-
■ equipment intended for use in domestic and non- where in hazardous areas without causing damage. Of
commercial environments course, some accidents have undoubtedly occurred.
■ personal protective equipment covered by the Although it is recognized that the risk is generally low
89/686/EEC directive for mechanical equipment installed in hazardous areas, the
■ seagoing vessels and mobile offshore units, such “European lawyer” of the European Community (today
as semisubmersible platforms and drilling jack gathering 25 European countries) has decided to include
up platforms, already covered by the Interna- mechanical equipment in ATEX 94/9/EC due to potential
tional Marine Organization (IMO) convention. friction and overheating. Although many pieces of
(Fixed platforms are included in the scope, as mechanical equipment are inherently safe (such as water
well as Floating, Production, Storage, Offload- pumps, air compressors in a Zone 2, etc.), the manufacturer
ing (FPSOs) units and units and vessels (below is obligated to demonstrate this safety. It is said by many
500 t) not intended for high seas (navigation on users that the “European lawyer” has decided to use the
river, lakes, etc.) “safety principle” pushed to the limit (as in no risk).
■ means of transport, except for vehicles intended for Ex mechanical equipment is now available on the
45
use in a potentially explosive atmosphere. market. In order for many pieces of mechanical
equipment to be used in a hazardous area, nothing Potential Ignition Sources and Other Hazards
must be changed and the manufacturer need only make to Be Controlled
a risk analysis to prove that there is no risk. In some The following represent potential hazards:
cases, a few modifications must be made (e.g., adjunc- ■ various sources of ignition, such as sparks, flames,
tion of temperature detectors). electric arcs, high surface temperatures, acoustic
To the author’s knowledge, no similar standards energy, optical radiation, or electromagnetic waves
for mechanical equipment exist in the American reg- ■ static electricity
ulations (NEC, etc.), but it cannot be said that Amer- ■ stray electric and leakage current
ican design of plant facilities is not safe. Are ■ overheating (friction, etc.)
Europeans being excessively (and unnecessarily) strin- ■ pressure compensation operations
gent in this field? ■ disturbance from external sources, such as overload-
ing, faults, changing environmental conditions, extra-
Dust Explosion Protection neous voltage, humidity, vibrations, or contamination
ATEX Directive 94/9/EC also includes dust as an explo- ■ software (fault in the program)
sive atmosphere. When standardization works started for ■ power failure
the dust ignition protection (DIP), it was assumed that ■ connections (conduits and cable entries).
dust explosion protection for electrical apparatus would Provisions are also made for specific requirements gov-
be mainly achieved by tight enclosures and limitation of erning devices used to provide additional equipment
surface temperature. For this reason, the degree of pro- safety.
tection Protection Index (IP) played an important role. These requirements necessitate detailed analysis to
The relevant IEC standards include the IEC 61241 assess the operational reliability of such devices and their
series, while the CENELEC standards include the EN interaction with other components connected with the
50281 series. The symbols originally intended for dust equipment.
explosion protection/DIP have been replaced by tD,
pD, iD, and mD, where D stands for dust ignition pro- Conformity Assessment Procedures
tection t stands for tight, and the other symbols (p, i, (Certification and Surveillance)
m) correspond to similar, but not identical, types of There are various conformity assessment procedures,
protection for gas. depending on equipment group and category, that enable
The prevention of ignition hazards caused by electro- the manufacturer to declare that the equipment and protec-
static discharges in Zone 21 is particularly important for tive systems comply with Directive 94/9/EC (see Figure 1).
dust explosion protection.
Equipment—Group II/Category 1
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ATEX Zones and Categories The manufacturer must follow the EC type-examination
The ATEX directive classifies equipment into categories procedure to affix the CE marking, in conjunction with the
depending on the level of safety requirement, the nature procedure for production quality assurance or the procedure
of inflammable substances, and the degrees of presence or for product verification. All these procedures are under the
duration of the explosive atmosphere. This classification Notified Bodies (NB’s) control and responsibility.
is summarized below, with the required level of protec- The EC type examination is the procedure by which an
tion and correlation with the code of hazardous areas NB ascertains and attests that a specimen representative of
commonly used worldwide. the production envisaged meets the relevant applicable
The link between the hazardous area (zone) and the cat- provisions of the directive.
egory of equipment is defined in ATEX Directive
1999/92/EC (Annex IIB). Equipment—Group II/Category 2
The various categories (1, 2, 3) of equipment must be In the case of internal combustion engines and electrical
capable of functioning in conformity with the operational equipment, the manufacturer must follow up the EC type-
parameters established by the manufacturer to a certain examination procedure with the procedure for conformity
level of protection. In all cases, the equipment remains to type or the procedure for product quality assurance.
energized and functioning in the designated zone. For other equipment (nonelectrical equipment), the
manufacturer must follow the procedure related to inter-
Caution! nal control of production and communicate the resulting
technical dossier to an NB, which shall acknowledge
For gas atmospheres: receipt of the dossier and retain the document.
Zone 0 requires category 1 equipment.
Zone 1 requires category 2 equipment. Equipment—Group II/Category 3
Zone 2 requires category 3 equipment. The manufacturer must follow the procedure for internal
control of production. The technical dossier must be avail-
For dust atmospheres: able for possible authorities to review, but does not have to
In the zone 22 area, conductive dust requires category 2 be communicated to the NB.
equipment and IP6X protection. In the zone 22 area, In addition to the procedures mentioned above (for
nonconductive dust requires category 3 equipment and categories 1–3), the manufacturer may also follow the
46
IP5X protection. procedure related to CE unit verification. The above
procedures are also applicable to components, with the No piece of equipment can be put on the market if the
exception of the affixing of the CE marking. manufacturer cannot deliver to the client the EC Declara-
■ As a general rule, for electrical equipment, if each prod- tion of Conformity.
uct cannot be individually inspected, the NB performs The declaration must include the following information:
an EC type examination and then periodically ensures ■ the name or identification mark and the address of
the conformity of equipment manufactured by means the manufacturer or his authorized representative
of a production or product quality assurance audit. established with the EU
■ The conformity assessment for equipment in group ■ a description of the explosion-protected equipment
II, category 3 (surface, zone 2/zone 22 application) (mark, type, serial number, etc.)
permits CE marking without intervention of an NB, ■ all relevant provisions fulfilled by the equipment
i.e., via the internal control of production. ■ where appropriate, reference to the harmonized
All other procedures, essentially health and safety proce- CENELEC standards
dures, rely on the expertise of the NBs to provide the ■ where appropriate, the national or international stan-
guarantee that the EHSRs have been met. This is not the dards and technical specifications that have been used
case for category 3. Greater responsibility is, therefore, ■ where appropriate, references to other European
placed on the manufacturer. directives that have been applied
■ where appropriate, the name, identification number,
Documents of Conformity and address of the NB and the number of the EC
type-examination certificate
Documents Issued by the Manufacturer ■ identification of the signatory who has been empow-
ered to enter commitments on behalf of the manu-
EC Declaration of Conformity facturer or his authorized representative established
Once the manufacturer has undertaken the appropriate within the EU.
procedures to assure conformity with essential require-
ments of the directive, it is the responsibility of the man- Written Attestation of Conformity for Components
ufacturer or his authorized representative established in In addition to declaring the conformity of components
the community to draw up a written EC Declaration of with the provisions of the directive, the Written Attesta-
Conformity for each manufactured product. In this decla- tion of Conformity must state the characteristics of the
ration, the manufacturer or his representative declares components and how the components are to be incorporat-
that the explosion-protected equipment placed on the ed into equipment or protective systems to ensure that the
market complies with all EHSRs. The undersigning of finished equipment or protective system meets the applic-
the EC declaration by the manufacturer or his representa- able EHSRs of the directive.

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tive authorizes them to affix the CE marking to the
equipment (it is not permitted to affix the CE marking Documents Accompanying the Product
to components). The EC Declaration of Conformity/Written Attestation

Serie Equipment
Examination
Prototype
Equipment Quality Assurance
Examination
Production Q.A.
EC Type Annex IV
Category Examination Or
1 by NB Product Verification
Annex III Annex V

Product Q.A.
Electrical EC Type Annex VII
Equipment Examination EC Declaration
and Internal by NB Or of Conformity
Combustion Engine Annex III Conformity to by Manufacturer
Category Type Annex VI
2
Internal Control
Nonelectrical of Production Communicate
by Manufacturer the Technical
Equipment Dossier to NB
Annex VIII

Internal Control
Category of Production
3 by Manufacturer
Annex VIII
1
47
Certification procedures in relationship with equipment category.
of Conformity must accompany the information given directives which all provide for the affixing of the
with each single product or batch of products. CE marking, the marking indicates that the prod-
All equipment or protective systems must be accompa- uct is presumed to conform to the provisions of all
nied by instructions that shall include these directives stated in the EC declaration of
■ repeat of the marking on the equipment, manufacturer’s equipment.
■ instructions for safe use and placement into service, The CE marking is mandatory and must be
■ assembly, dismantling, and maintenance instructions, affixed before any equipment or protective system is
■ indication of danger areas, placed on the market or put into service. The CE
■ characteristics of special tools, and marking is followed by the NB number, which is
■ all relevant drawings. related to the quality assurance of the manufacturer.
All of these instructions shall be translated into the lan- ■ Supplementary marking: Equipment, protective sys-
guage of the country where the equipment is installed. tems, and components must bear the specific mark-
This is applicable to all the EU countries. ing of explosion protection, the Epsilon x in a
hexagon, which is already known from the old
Documents Issued by the NB explosive atmospheres directive.
The NB shall deliver to the manufacturer an EC type- This marking must be followed by the symbol
examination certificate, including the name and address of of the group (II) and category (1, 2, or 3) of the
the manufacturer, conclusions of the examination, and the equipment and the letter G (concerning explo-
necessary data for the identification of the approved type. sive atmospheres caused by gases, vapours, and
In addition, the NB shall also issue the following qual- mists) and D (concerning explosive atmospheres
ity surveillance documents, according to the provisions of caused by dust).
the relevant conformity assessment procedures: ■ Additional marking: Equipment, protective sys-
■ production quality assurance notification tems, and components must be marked with all
■ product verification certificates the necessary information essential for safe use.
■ conformity to type notification The European standard series EN 50014 for elec-
■ product quality assurance notification trical products foresees a supplementary marking:
■ unit verification certificates. " the EEx symbol, which indicates that the prod-
These documents need not accompany the product. uct is in compliance with one or more stan-
dards of this series.
Marking of Equipment " the symbol for each type of protection (o, p, d,
Three types of markings are provided (see Figure 2): q, e, ia, ib, m, n).
■ CE marking: ATEX 94/9/EC, as well as the New " explosion group II A, II B, or II C in case of
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Approach directives, provide for the affixing of the type of protection d, i, or q.


CE marking as part of the conformity assessment " temperature class or maximum surface tem-
procedures. Where a product is subject to several perature.
■ Any equipment or protective
system accompanied by the
Example for Marking EC declaration of conformity
and bearing the CE marking
CE Marking Supplementary Marking Additional Marking as specified by the directive
Cε0081 εx II 2 G EEx d IIC T4 is considered by the member
CE Marking states to be in conformity
with EC Directive 94/9/EC.
Identification of the Notified Body Complementary Marking It does not indicate a certain
Responsible for the Approval. Specifying the Type of
0081 = LCIE (Example)
level of quality!
Protection ■ Components do not carry
The European Commission Mark CE marking but must be
for Ex Products EEx: Manufactured in Accordance covered by a Written
with CENELEC Standards. Attestation of Conformity.
■ Equipment bearing the CE
Equipment Group: II for Surface Ex: Manufactured in Accordance
Industry (I = mines) with IEC Standards.
conformity marking that
presents a safety risk is
Equipment Category: d: Mode of Protection : withdrawn from the mar-
1 for Zone 0 or 20, Explosion Proof. ket and prohibited by the
2 allowed for Zone 1 or 21 member states under a
3 for Zone 2 or 22 IIC: Apparatus Group. specified procedure.
■ If equipment bearing the CE
Atmosphere Surrounding the Equipment T4: Temperature Class.
G for Explosive Gas (D for Dust)
marking is found to be not
in conformity, action is taken
2 against those responsible for
48
Marking as per ATEX directive 94/9/EC. applying the marking.
Selection of Explosion-Protected Apparatus The benefit of having introduced categories in the direc-
tive is that, in the future, if a new type of protection is
Link Zone/Category offered by a technology development, there will be no need
ATEX Directive 1999/92/EC (Annex IIB) gives the to revise the directive. The corresponding standard for this
authorized category of equipment (1, 2, 3) in relation new type of protection shall indicate in its foreword the cate-
with the type of zone (0, 1, 2) where the equipment is gory to which it applies. This would not have been possible
installed, with a misleading shift between zone and with the old directive, which referred to specific standards; a
category (category 3 for zone 2!) (see Table 1). revision of the directive would have been necessary.

Link Category/Type of Protection Variable Speed Drives


The link between category and type of protection is given The updating of the CENELEC standards to incorporate
in the corresponding CENELEC standards. The foreword the requirements of the 94/9/EC directive has allowed the
states that this European standard covers essential require- introduction of rules for selection of motors associated with
ments of ATEX Directive 94/9/EC and provides protec- frequency converters (in the old directive, almost no such
tion in accordance with category (1, 2, 3, M1, or M2). rules existed). Depending on motor type, whether or not
For a given category, several types of protection are pro- the frequency converter is of the same manufacture as the
posed by the CENELEC standards (e.g., category 2 allows motor, and whether or not combined tests are required,
for “d,” “p,” “e,” etc. protection type; category 3 allows for additional devices may be required, such as thermistors to
“n” protection). It is up to the end user to select the appro- limit the motor surface temperature to a safe level. Also, for
priate type of protection. “d” motors, installation rules are precribed for motor

TABLE 1. RELATIONSHIP BETWEEN EQUIPMENT CATEGORY AND ZONE.


Presence or
Duration of
Category of Level of Protection Inflammable Explosive Correlation with
Group Equipment Faults to Allow For Substances Atmosphere Hazardous Areas
ATEX 94/9/EC ATEX 94/9/EC ATEX 1999/92/EC ATEX 1999/92/EC ATEX 1999/92/EC
Equipment M1
Group I M2
(Mines)

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Equipment 1 Very high level of Gas, vapours, Continuous Zone 0, 1, 2 gas
Group II protection mist, dust presence
(Surface) ------------
Two types of Long periods Zone 20, 21,
protection or two 22 dust
independent faults,
Rare faults Frequent
allowed for
2 High level of Gas, vapours, Likely to occur Zone 1, 2 gas
protection mist, dust
------------
One type, level Zone 21, 22 dust
of protection
Frequently occurring
disturbances, or
faults allowed for
3 Normal protection Gas, vapours, Unlikely to occur Zone 2 gas
------------ mist, dust
Required level of Present for a Zone 22 dust
protection for short period
normal operation 49
cabling to limit bearing currents, harmonics, and Electro- hesitate to affix the CE marking to a product for which
magnetic Compatibility (EMC) emissions. Motor loadabili- compliance with the EHSRs is questionable.
ty curves must sometimes be certified by an NB. Also, a It is the author’s opinion that there is a risk for decep-
second rating plate must be fitted on the motor frame. tion of the end user. The directive has made some provi-
sions for possible deviations and has provided for sanctions
ATEX Directive 1999/92/EC against guilty manufacturers, but this is not enough to
ATEX Directive 1999/92/EC aims to improve the health comfort the end user.
and safety protection of all workers potentially at risk from To avoid deviations made possible by the directive, the
explosive atmospheres and to ensure that workers enjoy a following provisions have been implemented.
minimum level of protection thoroughout all member
states. Duties are placed on the user (employer). There was Operator’s Requirements
no similar directive in the past (Old Approach). 1) Category 3 electrical equipment shall be required
The employer’s duties can be summarized as follows: to be “certified” by an NB. No “self certificate” by
■ prevention of the formation of explosive atmos- the manufacturer through internal control of pro-
pheres, avoidance of ignition sources, and mitigation duction shall be accepted. The document produced
of detrimental effects by the NB in these conditions is called a “state-
■ explosion risk assessment (likelihood of explosive ment of compliance” or “type examination certifi-
atmospheres, persistence, ignition sources, sub- cate” and not a EC type-examination certificate (as
stances used, and scale of the anticipated effects) for category 1 and 2 equipment).
■ classification of hazardous areas into zone 0/1/2 and 2) An EC type-examination certificate shall be requested
20/21/22 from the manufacturer for any category of equipment
■ training of workers (not required by the directive), in addition to the EC
■ written instructions and permits for work declaration of conformity (required by the directive).
■ explosion protection measures (appropriate working This document indicates, in particular, restrictions of
clothes in dust areas of nonelectrostatic type, escape use (if any) and often provides useful information.
facilities, etc.) 3) Only CENELEC standards (harmonized or not)
■ warning signs for locations where explosive atmos- shall be recognized. IEC standards shall be accept-
pheres may occur ed, provided they are identical to the CENELEC
■ preparation of the explosion protection document ones, which is not the case today. The new genera-
(EPD), including all the above provisions, for tion of CENELEC standards incorporate the ATEX
possible review by authorities directive requirements. IEC and CENELEC stan-
■ ensuring all hazardous area workplaces used for the dards should become identical in the future, thanks
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first time after 30 June 2003 comply with the to the Dresde agreement, using a “copy and paste”
appropriate minimum requirements of ATEX procedure between IEC and CENELEC standards.
Directive 1999/92/EC The existing CENELEC standards EN 50014 and
■ ensuring all existing hazardous area workplaces in upwards are going to be repealed and replaced
use before 30 June 2003 comply with the appropri- gradually by the EN 60079 series, identical or very
ate minimum requirements of ATEX Directive similar to the IEC 60079 series. Other standards
1999/92/EC no later than 30 June 2006. shall be subject to formal operator approval.
It is ATEX Directive 1999/92/EC in its annex IIB which 4) When the manufacturer is not very well known by
gives the relationship between zone and category. the operator or when there is some doubt about the
quality/safety of the proposed product, then,
The Operator’s Viewpoint depending on equipment category, a “production
ATEX Directive 94/9/EC opens the door to innovation quality assessment notification” (for category 1) or a
since any standard may be used, removing technical bar- “product quality assurance notification” (for cate-
riers to trade and allowing free movement of products. gory 2) shall be required by the operator from the
The product has to meet “only” EHSRs. The con- manufacturer. These documents have been delivered
formity assessment to the directive is made by an NB by the NB to the manufacturer after successful
only for category 1 and 2 equipment. Category 3 audit at the manufacturer’s works. The provisions
equipment (for zone 2 area), which represents about made by the ATEX directive for quality audit at
80% of the equipment installed in the hazardous areas the manufacturer’s works are new and are credited
at the operator exploration/production facilities, may by users with granting better confidence in the
be self certified by the manufacturer, and this is per- quality of products. Yet, it is regrettable that noth-
haps a source of risk as greater responsibility is placed ing has been provided for category 3 equipment,
on the manufacturer. which includes many bulk materials (junction
Manufacturers installed outside Europe, through their boxes, sockets, and luminaires), perhaps because the
authorized representative installed in the community, are explosion risk is considered lower. This is not in
authorized to affix the CE marking, which is the passport line with the aim of the directive, which is to
to Europe. There is the possibility of fraud from not very increase the level of safety.
scrupulous foreign manufacturers or their authorized rep- 5) For mechanical equipment (rotating equipment
50
resentatives, who may be the importer and who may not such as pumps, compressors, fans, gears, valves,
etc.) in categories 2 and 3, self certification by at the operator’s exploration/production facilities
the manufacturer shall not be accepted. As for (onshore and offshore).
electrical equipment, a statement of compliance A major effort is still to be carried out for employee
issued by an NB shall be required. For category 2 training at the head office and at production sites in the
mechanical equipment, the ATEX directive operator’s various affiliates. This includes not only the
requires that the manufacturer communicate to electrical and instrumentation engineers, but also the
the NB the technical documentation to be kept mechanical engineers.
only as archive and opened only in case of need. The topic is not closed; many discussions are still in
It is rather surprising that the NB has not been progress with various partners, including public authori-
requested to verify the content and validity of ties. Although several documents have been prepared by
the documents submitted by the manufacturer. the European Commission to be used as guidelines for
Experience being limited in this domain for all users in addition to the official texts, there are still grey
involved parties, the input of the NB would areas for users (valves, variable speed drives, mechanical
surely have been beneficial. equipment). In France, a special committee (CLATEX)
6) Application inside the EU countries is obviously with Industry and Department of Labor representatives
mandatory. answers questions raised by users and manufacturers.
7) Application outside the EU countries has been made Attaining the answer often becomes a project, and some-
mandatory by the operator’s decision for the follow- times the question must be discussed at the European
ing reasons: Commission level.
" Most of the manufacturers apply the ATEX direc- Also, some “trade documents,” which are practical
tive requirements and propose products as “ATEX guides for the ATEX directive implementation, have
certified.” become available, while other documents are under
" Several American manufacturers of packages (such preparation per branch of activity (chemical industries,
as turbo generators) are able to handle the new refining, etc.).
ATEX directive. For the future, the IECEx scheme, which is an interna-
" It is difficult for the operator to accept two differ- tional certification scheme under development and discus-
ent standards/regulations originating in different sion by several countries, might bring a solution to avoid
countries (inside and outside Europe). recertifying/retesting regardless of previous assessments
" If the new ATEX directive was not applied outside due to national standards and certification schemes. How
Europe, the only way to “certify” equipment the ATEX directive conformity assessment procedures
would be to accept a Certificate of Conformity to could be integrated in this IECEX scheme—to get at last
IEC standards (the old directives being repealed, a single and unique worldwide certification scheme—is

IEEE INDUSTRY APPLICATIONS MAGAZINE • JAN|FEB 2007 • WWW.IEEE.ORG/IAS


no certificate based upon the old CENELEC stan- still a question to be discussed.
dards can be obtained). Today, most of the manu- Yet, it seems that the IECEX scheme would be more or
facturers produce equipment in conformity with less a “copy and paste” of the ATEX directive. Again, it is
CENELEC standards. regrettable that, as for the ATEX directive, nothing has
Apparently, the ATEX directive is becoming a de been provided for category 3 equipment as far as quality
facto international standard rather than solely a audit at the manufacturer’s works is concerned.
European one, as many non-European countries rec- The ATEX directives open a new era with the concept
ognize the ATEX directive. of the “New Approach.” They open the way to innova-
8) The operator is surprised with the number of NBs, tion, with standards no longer being technical barriers.
which has rapidly increased, going from a dozen to More responsibility is now placed on the end user for the
about 55 today! Many newcomers are unknown by proper selection of equipment and, perhaps, of NB. This
the majority of users, and the number of NBs is is in line with a general trend found in other domains,
going to increase in the near future with the enlarge- where the responsibility is more and more on the end
ment of the EU. The operator wonders whether the user’s shoulders, regardless of the technical provisions that
competence of all these NBs will be identical, have been taken. A greater vigilance for the next two to
although it is so on paper! No sufficient harmonized three years is advisable to allow all the involved parties to
practices can really be expected between all these become familiar with all of the new concepts.
NBs, and cost for the “same service” may be quite
different without the guarantee that the expected References
safety level for Ex-certified products is actually met. [1] ATEX directive 94/9/EC, “European Directive 94/9/EC (23/03/94) on the
At last, it must be remembered that each NB is approximation of the laws of the Member States concerning equipment and
protective systems intended for use in potentially explosive atmospheres”.
responsible for a list of selected products and for cer- [2] ATEX directive 1999/92/EEC, “European Directive 1999/92/EEC
tification modules according to a certain number of (16/12/99) on minimum requirements for improving the safety and health
annexes in the directive. protection of workers potentially at risk from explosive atmospheres”.>

Conclusions Patrick Leroux is with TOTAL Exploration/Production in


With all the above additional precautions to make sure Paris, France. This article first appeared as “The Operator’s
that there is no deviation from the spirit of the directive, Viewpoint of the ATEX Directive 94/9/IEC” at the 2005
51
the ATEX 94/9/EC Directive shall be applied worldwide Petroleum and Chemical Industry Conference.

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